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CMS Says Multiple Students Can Participate in Patient Care and Documentation

STFM Proposes Scenarios for Further Clarity of Student Documentation Guidelines

May 15, 2019—On April 26, CMS issued a new transmittal, R4283CP, to "clarify existing manual language to bring the manual in line with current payment policy for teaching physicians providing evaluation and management services."

Specifically, the transmittal replaced the word "student" with "students," putting to rest any question about whether multiple students can be involved in a patient's care and documentation. The transmittal also has new language stating, "The patient medical record must document the extent of the teaching physician’s participation in the review and direction of the services furnished to each beneficiary. The extent of the teaching physician’s participation may be demonstrated by the notes in the medical records made by physicians, residents, or nurses."

On May 15, STFM responded to a request from CMS for information on any ongoing member concerns or confusion about interpretation of the student documentation guidelines. STFM noted that there are various interpretations of "physical presence," and a lack of clarity about resident involvement when a student is also involved in patient care. In some cases, this confusion has hindered implementation of the guidelines. STFM proposed several scenarios that would provide clearer interpretation.

STFM also encouraged CMS to change its policy regarding the inclusion of Advanced Practice Nurses/Physician Assistant students AND preceptors.